- 5 - 
have attempted to demonstrate the relatively little likelihood that the 
organisms will escape-from the laboratory, and that if they do escape, 
probably will not survive. No consideration has been given to the 
harm to Appellant, and his environment, if Appellees' attempts in this 
regard are unsuccessful. 
Appellant requests that this Court enjoin Appellees , from conducting 
at Ft. Detrick, Maryland, proposed experiments on the Biological 
Properties of Polyoma Recombinant DNA Cloned in Bacterial Cells, until 
this Court has had an opportunity to rule on Appellant's appeal from the 
decision of the United States District Court for the District of Columbia 
Circuit denying his motion for a preliminary injunction. Counsel for 
Appellees has advised counsel for Appellant that laboratory preparations 
will commence on February 27 or 28, and the actual experiments in 
question will begin in about two weeks. Unless there is continuity in 
the injunction, the genie may be let out of the bottle, beyond the recall 
of an order of this, or any other, court. 
RELIEF SOUGHT 
Ferdinand J. Mack 
17 West Jefferson Street 
Suite 106 
Rockville, Maryland 20850 
Attorney for Appellant 
[Appendix C — 19] 
